OMB# 1076-0178 - NABDI Supporting Statement 2017

Supporting Statement A

Native American Business Development Institute (NABDI) Funding Solicitations and Reporting

OMB Control Number 1076-0178

Terms of Clearance: None.

General Instructions

A completed Supporting Statement A must accompany each request for approval of a collection of information. The Supporting Statement must be prepared in the format described below, and must contain the information specified below. If an item is not applicable, provide a brief explanation. When the question “Does this ICR contain surveys, censuses, or employ statistical methods?” is checked "Yes," then a Supporting Statement B must be completed. OMB reserves the right to require the submission of additional information with respect to any request for approval.

Specific Instructions

Justification

1. Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection.

The Office of Indian Energy and Economic Development (IEED) has established the Native American Business Development Institute (NABDI) to provide technical assistance funding on a competitive basis to federally recognized American Indian Tribes seeking to retain universities and colleges, private consulting firms, non-academic/non-profit entities, or others to perform feasibility studies of economic development. These feasibility studies will empower American Indian Tribes and tribal businesses to make informed decisions regarding their economic futures. Feasibility studies may concern the viability of an economic development project, marketing scheme, or business or the practicality of a technology a Tribe may seek to acquire or market.

This is an annual program whose primary objective is to create jobs and foster economic activity within tribal communities. When funding is available, IEED will solicit proposals for economic development feasibility studies. Selected applicants will receive their awards by way of discretionary (not Public Law 93-638) grants.

Interested applicants must submit a tribal resolution requesting funding, a statement of work describing the project for which the feasibility study is requested, and a budget indicating the funding amount requested and how it will be spent. Quarterly summary reports and a final report must be submitted grants Awarding Official at the conclusion of the project describing the work that was completed and any final thoughts/recommendations.

2. Indicate how, by whom, and for what purpose the information is to be used. Except for a new collection, indicate the actual use the agency has made of the information received from the current collection. Be specific. If this collection is a form or a questionnaire, every question needs to be justified.

IEED will use the information provided by applicants to determine whether they are eligible for NABDI funding. IEED will also use applicant information in conjunction with the information provided in the Tribe’s final report to determine whether the Tribe is using the funding for the stated purpose of tribal enterprise and/or business development studies. The information is not disseminated to the public or used to support information that will be disseminated to the public.

The instrument for collecting the information will be a solicitation placed on Grants.gov. The solicitation states that there are three mandatory components to an application:

• Tribal resolution: IEED uses this document to confirm that the recognized governing body of the Tribe has authorized the request for funding and the purpose for which the funding will be used.

• Statement of work: IEED uses this document to ensure that the Tribe plans to use the funding only for authorized purposes in the appropriate fiscal year. IEED will also refer to the Statement of Work in reviewing the proposal against the ranking criteria identified in the Grants.gov solicitation.

• Detailed budget estimate: IEED will review the budget estimate to determine whether the budget is reasonable and can produce the results outlined under the proposal and to determine the cost-benefit ratio, in accordance with the ranking criteria identified in the Grants.gov solicitation.

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IEED also requires quarterly reports and a final report. IEED uses the information in these reports to ensure the project is progressing and that funds are being used for appropriate purposes.

3. Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection techniques or other forms of information technology, e.g., permitting electronic submission of responses, and the basis for the decision for adopting this means of collection. Also describe any consideration of using information technology to reduce burden and specifically how this collection meets GPEA requirements.

IEED accepts applications and reports electronically submitted to the email address shown in the Grants.gov solicitation, and by regular mail. Faxed applications are not accepted.

4. Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use for the purposes described in Item 2 above.

The information that IEED collects is not available from any other source. The information collected is unique to each Tribe and to each Tribe’s plans for tribal economic development.

5. If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden.

Indian Tribes are not considered small entities, but they may finance small businesses that conduct tribal business. To ensure that the burden of providing information is minimized, IEED collects only information that is necessary for it to determine whether a Tribe is eligible for funding and whether the funding is being appropriately spent.

6. Describe the consequence to Federal program or policy activities if the collection is not conducted or is conducted less frequently, as well as any technical or legal obstacles to reducing burden.

If IEED were unable to conduct this information collection, Tribes would be deprived of funding for feasibility studies that are often necessary to obtain project financing. As a consequence, many Tribes that otherwise would be recipients of this funding would not be able to perform tribal economic development studies, depriving them of the opportunity to build sustainable economies.

7. Explain any special circumstances that would cause an information collection to be conducted in a manner:

* requiring respondents to report information to the agency more often than quarterly;

* requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it;

* requiring respondents to submit more than an original and two copies of any document;

* requiring respondents to retain records, other than health, medical, government contract, grant-in-aid, or tax records, for more than three years;

* in connection with a statistical survey that is not designed to produce valid and reliable results that can be generalized to the universe of study;

* requiring the use of a statistical data classification that has not been reviewed and approved by OMB;

* that includes a pledge of confidentiality that is not supported by authority established in statute or regulation, that is not supported by disclosure and data security policies that are consistent with the pledge, or which unnecessarily impedes sharing of data with other agencies for compatible confidential use; or

* requiring respondents to submit proprietary trade secrets, or other confidential information, unless the agency can demonstrate that it has instituted procedures to protect the information's confidentiality to the extent permitted by law.

There are no circumstances that require IEED to collect the information in a manner inconsistent with OMB guidelines.

8. If applicable, provide a copy and identify the date and page number of publication in the Federal Register of the agency's notice, required by 5 CFR 1320.8(d), soliciting comments on the information collection prior to submission to OMB. Summarize public comments received in response to that notice and in response to the PRA statement associated with the collection over the past three years, and describe actions taken by the agency in response to these comments. Specifically address comments received on cost and hour burden.

A 60-day notice for public comments was published in the Federal Register on July 26, 2017 (82 FR 34686). No comments were received in response to this notice.

Describe efforts to consult with persons outside the agency to obtain their views on the availability of data, frequency of collection, the clarity of instructions and recordkeeping, disclosure, or reporting format (if any), and on the data elements to be recorded, disclosed, or reported.

Consultation with representatives of those from whom information is to be obtained or those who must compile records should occur at least once every three years — even if the collection of information activity is the same as in prior periods. There may be circumstances that may preclude consultation in a specific situation. These circumstances should be explained.

We received the following feedback from tribal representatives regarding the information collection.

A representative from the Elko Band of the Te Moak Tribes stated that the NABDI grant took them 40-50 hours to complete, research time not included. There were three people that worked on the grant application and their salaries ranged between $22 and $24 per hour.

A representative from the Tonkawa Tribe of Oklahoma stated that the NABDI grant took them about two weeks to complete, a total of about 60 hours. The salary of the one person who worked on this is $26 per hour.

A grant writer for Forest County Potawatomi stated that the NABDI grant application took approximately 60 hours to complete. The average salary of the people working on the application is within the $22-30 per hour range.

As a result of the feedback IEED received regarding the burden hours associated with the application, the burden hours have been increased in the table below. However, IEED acknowledges that the solicitation does not request a uniform format on what information is needed from tribes. Therefore, some tribes certainly do put in more time and effort to collect information and submit the application. There were several formats that were used that were streamlined and probably took about 10 hours to complete. Several of those were funded. In the future, IEED will be working to streamline the application process for Tribes and work to provide more guidance on what information is necessary in the application.

9. Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.

No payments or gifts are provided to respondents.

10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy.

IEED does not provide any assurance of confidentiality. The information that IEED collects is subject to the requirements of the Privacy Act and the Freedom of Information Act.

11. Provide additional justification for any questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private. This justification should include the reasons why the agency considers the questions necessary, the specific uses to be made of the information, the explanation to be given to persons from whom the information is requested, and any steps to be taken to obtain their consent.

There are no questions of a sensitive nature included in the information collected.

12. Provide estimates of the hour burden of the collection of information. The statement should:

* Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated. Unless directed to do so, agencies should not conduct special surveys to obtain information on which to base hour burden estimates. Consultation with a sample (fewer than 10) of potential respondents is desirable. If the hour burden on respondents is expected to vary widely because of differences in activity, size, or complexity, show the range of estimated hour burden, and explain the reasons for the variance. Generally, estimates should not include burden hours for customary and usual business practices.

* If this request for approval covers more than one form, provide separate hour burden estimates for each form and aggregate the hour burdens.

* Provide estimates of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories. The cost of contracting out or paying outside parties for information collection activities should not be included here.

We anticipate receiving approximately 20 applications each year, at 50 burden hours each, for a total of 1,000 hours. In addition, we anticipate accepting 20 applications (based on funding available) and each of those project participants will submit a final report at 1.5 hours per report, for a total of 30 burden hours. This totals 1,030 hours or the amount equivalent to $35,947.

Regulation/ Activity	Annual Number of Responses	Completion Time (hours) Per Response	Total Annual Burden Hours	Hourly Rate w/ Benefits (1.4 multiplier)	$ Value of Annual Burden Hours
Applications – Tribal Govt	20	50	1,000	$34.90	$ 34,900
Final Report - Tribal Govt	20	1.5	30	$34.90	$ 1,047
Totals	40		1,030		$35,947

To obtain the hourly rate, BIA used $34.90, the wages and salaries figure for civilian workers from BLS Release USDL-17-0321, Employer Costs for Employee Compensation—December 2016, Table 1, Employer costs per hour worked for employee compensation and costs as a percent of total compensation: Civilian workers, by major occupational and industry group, at https://www.bls.gov/news.release/pdf/ecec.pdf. This wage includes a multiplier for benefits. See www.bls.gov/news.release/pdf/ecec.pdf.

13. Provide an estimate of the total annual non-hour cost burden to respondents or recordkeepers resulting from the collection of information. (Do not include the cost of any hour burden already reflected in item 12.)

* The cost estimate should be split into two components: (a) a total capital and start-up cost component (annualized over its expected useful life) and (b) a total operation and maintenance and purchase of services component. The estimates should take into account costs associated with generating, maintaining, and disclosing or providing the information (including filing fees paid for form processing). Include descriptions of methods used to estimate major cost factors including system and technology acquisition, expected useful life of capital equipment, the discount rate(s), and the time period over which costs will be incurred. Capital and start-up costs include, among other items, preparations for collecting information such as purchasing computers and software; monitoring, sampling, drilling and testing equipment; and record storage facilities.

* If cost estimates are expected to vary widely, agencies should present ranges of cost burdens and explain the reasons for the variance. The cost of purchasing or contracting out information collection services should be a part of this cost burden estimate. In developing cost burden estimates, agencies may consult with a sample of respondents (fewer than 10), utilize the 60-day pre-OMB submission public comment process and use existing economic or regulatory impact analysis associated with the rulemaking containing the information collection, as appropriate.

* Generally, estimates should not include purchases of equipment or services, or portions thereof, made: (1) prior to October 1, 1995, (2) to achieve regulatory compliance with requirements not associated with the information collection, (3) for reasons other than to provide information or keep records for the government, or (4) as part of customary and usual business or private practices.

We have not identified any non-hour costs associated with this information collection.

14. Provide estimates of annualized cost to the Federal government. Also, provide a description of the method used to estimate cost, which should include quantification of hours, operational expenses (such as equipment, overhead, printing, and support staff), and any other expense that would not have been incurred without this collection of information.

We estimate the annual cost to the Federal Government to administer this information collection to be $17,050. This includes $16,350 in salary costs (see table below) and $700 in paper and mailing costs.

Regulation/ Activity	Completion Time (hours)	Total Annual Burden Hours	Hourly Rate w/ Benefits (1.5 multiplier)*	$ Value of Annual Burden Hours
Registration administration	150	150	$54.50	$ 8,175
Collect and Assess Data	150	150	$54.50	$ 8,175
Totals		300		$ 16,350

Using the 2017 General Schedule, the hourly rate for a GS-12/step 5 is $54.50 including benefits ($34.06 hourly rate multiplied by 1.6 to account for benefits). See https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/17Tables/html/GS_h.aspx.

15. Explain the reasons for any program changes or adjustments in hour or cost burden.

As stated above, the burden hours have been increased in the table above. However, IEED acknowledges that the solicitation does not request a uniform format on what information is needed from tribes. Therefore, some tribes certainly do put in more time and effort to collect information and submit the application. There were several formats that were used that were streamlined and probably took about 10 hours to complete. Several of those were funded.

16. For collections of information whose results will be published, outline plans for tabulation and publication. Address any complex analytical techniques that will be used. Provide the time schedule for the entire project, including beginning and ending dates of the collection of information, completion of report, publication dates, and other actions.

We will not publish the results of this information collection

17. If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.

We will display the OMB control number and expiration date on the solicitation for proposals as well as on other appropriate materials.

18. Explain each exception to the topics of the certification statement identified in "Certification for Paperwork Reduction Act Submissions."

There are no exceptions.

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